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You may need to make sure the console has plenty of room for air to flow around and through the system without being restricted. I had mine in a cabinet for a while and as long as the door was open it was fine but if the door got closed by accident the fans would get louder than usual.
There is also a feature built into the PS3 that shuts the system down before it over heats to allow the console to cool down. I have found that the PS3 does stay a little cooler by haveing it standing vertical. If this is not the problem you may want to call Sony and go through some test over the phone to make sure the fan is working in the console because the fan is so quite most of the time it's hard to hear unless it kicks up to the high speed (even then it's not very loud).
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